Mission Funding Alpha v. Commonwealth of PA

OPINION BY

Judge ANNE E. COVEY.. Mission Funding Alpha (MFA) petitions this Court- for review of the Board of Finance- and Revenue’s (Board) March 27, 2012 order sustaining the Board of Appeals’ (Appeals Board) order dismissing MFA’s Pennsylvania Foreign Franchise Tax (Franchise Tax) refund claim as untimely. The- sole issue before the Court is whether the Board erred in concluding that April 15, 2008 was the date on which MFA made its "actual payment of the tax” under 'Section 3003.1(a) of the Tax Reform Code of 1971 (Tax Reform Code). 1 Upon review, we reverse.

Pursuant to Rule 1571(f) of the…